Frequently Asked Questions

789. May persons subject to U.S. jurisdiction who open an authorized business or physical presence, such as a joint venture, office, or retail outlet, in Cuba market their telecommunications or internet-based services?

789 … Persons subject to U.S. jurisdiction that are providers of telecommunications or internet-based services who establish a business or physical presence in Cuba pursuant to the authorization in 31 CFR § 515.573 are authorized to engage in marketing related to that business or physical presence… Read more

790. Are persons subject to U.S. jurisdiction engaging in authorized transactions permitted to enter into arrangements with Cuban state-owned entities, such as ETECSA?

790 … Individuals or entities subject to U.S. jurisdiction engaging in authorized transactions, either pursuant to a general or specific license, may engage with Cuban state-owned entities as authorized by the OFAC license. For example, a U.S. company engaging in authorized telecommunications-… Read more

791. Are Cuban nationals located outside of Cuba still considered blocked?

791 … Yes, but any individual Cuban national who can establish that he or she has taken up permanent residence outside of Cuba and otherwise meets the requirements set forth in 31 CFR § 515.505 is generally licensed as an unblocked national. Additionally all persons subject to U.S. jurisdiction are… Read more

792. Can U.S.-owned or -controlled entities in third countries engage in trade/commerce with Cuban nationals located outside of Cuba?

792 … U.S.-owned or -controlled entities in third countries may provide goods and services to a Cuban national located outside of Cuba, provided that the transaction does not involve a commercial exportation, directly or indirectly, of goods or services to or from Cuba. For a complete description… Read more

793. Are persons subject to U.S. jurisdiction authorized to provide financial services to Cuban nationals located outside of Cuba?

793 … Yes. Persons subject to U.S. jurisdiction may provide financial services to a Cuban national located outside of Cuba who is an individual, provided that the transaction does not involve a commercial exportation, directly or indirectly, of goods or services to or from Cuba. Additionally,… Read more

794. What types of grants or awards in which Cuba or a Cuban national has an interest are authorized for persons subject to U.S. jurisdiction to provide?

794 … Section 515.590 of the CACR authorizes the provision of certain grants, scholarships, or awards to Cuban nationals or in which Cuba or a Cuban national has an interest. Such grants, scholarships, or awards must relate to educational activities, certain humanitarian projects (as set forth in… Read more

795. Can a grant authorized pursuant to the CACR be awarded to a Cuban state-owned entity?

795 … Section 515.590 of the CACR authorizes the provision of grants, scholarships, or awards to a Cuban national, including a Cuban state-owned entity provided that entity is not included on the State Department’s Cuba Restricted List , and as long as any such grant, scholarship, or award is… Read more

796. Are specific licenses still required for transactions relative to the administration of a Cuban estate?

796 … Section 515.523 of the Cuban Assets Control Regulations authorizes all transactions incident to the administration and distribution of the assets of a blocked estate of a decedent. All property distributed pursuant to 31 CFR § 515.523 is unblocked, provided that neither Cuba nor a Cuban… Read more

797. What types of projects would fall within the authorization in 31 CFR §515.575 for microfinancing projects?

797 … Among other things, the provision for microfinancing projects in section 515.575 of the Cuban Assets Control Regulations (CACR) authorizes the provision of certain financial services to unemployed, underemployed, and low-income Cubans who have little or no access to conventional banks or… Read more

798. If a person had applied for a specific license from OFAC before the CACR was revised but now believes that the proposed activity is authorized pursuant to a general license, does that person need to wait for his or her specific license application to be adjudicated?

798 … No. If persons meet the qualifications listed in the general license, then they do not need to wait for an official determination from OFAC regarding their specific license application. Persons who have determined they may proceed under a general license may wish to contact OFAC Licensing to… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence